Tax Controversy
From its inception until its conclusion, a tax controversy will present a number of important decisions for the practitioner to make. In many situations no clear answer will be apparent. Each such decision, however, can significantly affect the outcome of the tax dispute for the taxpayer. That is why it is critical to choose a attorney with the requisite experience and skill necessary to achieve the most beneficial outcome for you, the taxpayer. Our firm handles tax controversies at all levels from the inception of an IRS audit to courtroom litigation.
There are two basic types of litigation that can be commenced by a taxpayer: (1) deficiency litigation, and (2) refund actions. Deficiency litigation takes place in the Tax Court where the issuance of a statutory notice of deficiency identifying a proposed tax liability is the sole jurisdictional prerequisite and prior payment of the deficiency is not required. Refund actions, on the other hand, are conducted in the United States district courts or the United States Court of Federal Claims and must be premised on payment of the full amount of the tax in dispute and the timely filing of a claim for refund.
Because of the financial burden refund actions impose on clients, the Tax Court is, generally speaking, the most cost efficient forum for litigation, and it is the forum preferred by our firm. We are, however, able and willing to litigate your tax case in other forums if appropriate.
In many instances, however, a tax dispute can be resolved prior to the commencement of formal court proceeds. Audit appeals, requests for innocent spouse relief, offers in compromise, and collection due process hearings are alternative means to resolving disputes with the IRS. We are experienced with all of these methods of dispute resolution and would be happy to consult with you about these procedures.
Whether your case can be resolved through the alternative methods referenced above, or whether you require a trial in federal court, the professionals at J. L. Williamson Law Group, LLC, have the expertise and commitment to represent you at all stages of your tax dispute with the IRS.